Legal Opinion

Lackey v. Commissioner

United States Tax Court

Decided July 12, 1977No. DOCKET NO. 835-74Unpublished

Petitioner E. Gerald Lackey was the president of Corporation A, Corporation T and Corporation P, and a minority shareholder of the first two corporations. He made charitable contributions of the stock of Corporation A in both 1968 and 1969. The stock of Corporation A became worthless in 1970. Held, the fair market value of the stock contributions determined.

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Petitioner E. Gerald Lackey was the president of Corporation A, Corporation T and Corporation P, and a minority shareholder of the first two corporations. He made charitable contributions of the stock of Corporation A in both 1968 and 1969. The stock of Corporation A became worthless in 1970. Held, the fair market value of the stock contributions determined. Petitioners were indebted to a bank for over $300,000. In 1970 the bank foreclosed on the collateral securing petitioners' indebtedness. Held, all the property sold by the bank was owned either jointly or severally by petitioners. No…

1Opinion of the Court

E. GERALD LACKEY and MARY JANE LACKEY, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Lackey v. Commissioner

DOCKET NO. 835-74.

United States Tax Court

T.C. Memo 1977-213; 1977 Tax Ct. Memo LEXIS 229; 36 T.C.M. (CCH) 890; T.C.M. (RIA) 770213;

July 12, 1977, Filed

Petitioner E. Gerald Lackey was the president of Corporation A, Corporation T and Corporation P, and a minority shareholder of the first two corporations. He made charitable contributions of the stock of Corporation A in both 1968 and 1969. The stock of Corporation A became worthless in 1970. Held, the fair market value of the…

2Cases cited62 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
  3. Commissioner v. FlowersSupreme Court of the United States · 1946
  4. Crane v. CommissionerSupreme Court of the United States · 1947
  5. United States v. CorrellSupreme Court of the United States · 1967

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